If you sell products online to customers elsewhere in the EU, you may recently have encountered an alarming claim: under the new Packaging and Packaging Waste Regulation, or PPWR, sellers supposedly have to register in every EU country they ship to — at a cost of around €1,000 per country.
There is a real problem behind the claim.
But there is no €1,000 EU registration fee in the PPWR.
What the new rules actually create is potentially more troublesome for a small seller: separate packaging compliance obligations in each EU country in which the seller is considered the “producer”, combined in certain cross-border cases with an obligation to appoint a local authorised representative.
Those representatives, registrations, recycling schemes and compliance services can cost money. For a business selling only a handful of parcels into each country, the fixed administrative costs can easily become disproportionate to the revenue generated there.
And yes: the European Commission itself recognised the problem and proposed suspending one of the most burdensome requirements. EU Member States have so far refused to proceed with that proposal.
Here is what is actually happening.
What is the PPWR?
The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 — is the EU’s new framework for packaging.
It entered into force on 11 February 2025 and has applied generally since 12 August 2026. Some important requirements, including recyclability standards, recycled-content rules, packaging minimisation measures and various reuse targets, only take effect later.
Its objectives are fairly straightforward: reduce packaging waste, improve recycling, reduce unnecessary packaging, increase recycled material use and make whoever places packaging on a market contribute to the cost of dealing with it when it becomes waste.
That last part is known as Extended Producer Responsibility, or EPR.
EPR itself is not new. EU countries already operated national packaging responsibility schemes before the PPWR. What PPWR does is establish a more uniform EU framework while retaining an important national element: packaging waste is still dealt with in the country where it becomes waste.
And that is where cross-border ecommerce becomes complicated.
Selling across the EU does not create one EU-wide packaging registration
The EU Single Market might suggest that a business should be able to obtain one packaging registration and then sell throughout the Union.
That is not what the PPWR currently provides.
Article 44 says producers must register in each Member State where they first make packaging or packaged products available. Article 45 then establishes the corresponding EPR responsibility for that packaging.
The Commission’s own guidance explains the principle quite clearly: the producer is responsible for registration, reporting and EPR costs in the Member State where the packaging is expected to become waste.
So if an online shop established in Croatia sends packaged products directly to end users in Germany, Austria and France, it can potentially have packaging-EPR obligations in Germany, Austria and France.
The crucial words are directly to end users.
Under the PPWR, an end user can be a private consumer, but it can also be a professional customer that uses the product rather than reselling it. A sale to a distributor that subsequently resells the goods is therefore not necessarily treated in the same way as a direct ecommerce sale to the eventual user.
The particularly controversial rule: a representative in every destination country
This is the provision causing much of the current controversy.
Article 45(3) says that an EU producer selling directly to end users in another Member State must appoint an authorised representative for extended producer responsibility in that Member State.
Consider an EU-based webshop selling directly to customers in ten other EU countries.
Under the current rule, that can potentially mean:
– packaging obligations in ten countries;
– national EPR arrangements in ten countries;
– reporting packaging quantities by country;
– and ten authorised representatives.
For a multinational corporation, that is a compliance department problem.
For a two-person webshop, it can be a reason to stop selling internationally.
The European Commission itself acknowledged precisely this problem. In its December 2025 proposal to suspend the representative requirement, it described the need to appoint representatives in potentially numerous Member States as a significant administrative burden and an obstacle within the Single Market.
So where does the “€1,000 per country” come from?
Not from the PPWR.
There is no provision in Regulation 2025/40 imposing a €1,000 registration fee per country.
Article 44 says that national authorities may charge a fee for processing registration applications, but that fee must be cost-based and proportionate.
Germany illustrates the distinction particularly well.
Germany’s official Central Agency Packaging Register states explicitly that registration in its LUCID Packaging Register is free of charge. A producer may separately need to pay for participation in a recycling system, but the government registration itself costs nothing.
So why is €1,000 circulating online?
Because that is approximately what some commercial compliance providers charge.
One provider currently advertises a package at €1,000 per country per year, including EPR registration, reporting, authorised representation and compliance monitoring.
That is a commercial service price.
It is not an EU tax, statutory registration fee or fixed PPWR charge.
Actual costs can therefore vary significantly between countries and providers. They can include several different components:
– registration;
– an authorised representative;
– membership of a producer responsibility organisation;
– recycling or system-participation fees;
– reporting;
– consultancy or compliance-provider fees.
Conflating all of these into a supposed “€1,000 EU registration fee” makes for an effective social-media headline, but it is legally inaccurate.
Unfortunately, the underlying problem for small sellers is still real
Suppose — purely as an illustrative example — a small Croatian webshop sends occasional orders directly to consumers in Germany, Austria and France.
If the webshop is the producer for EPR purposes in those countries, it may need to satisfy three different national packaging regimes and, under the current Article 45 rule, appoint representatives in those three destination countries.
If it voluntarily buys a commercial compliance package priced at €1,000 per country, that example business would spend €3,000 per year before considering the underlying recycling contributions.
Again, €3,000 is an example based on one publicly advertised commercial price, not a fee required by EU law.
For a company doing €500,000 of sales in each country, that may be manageable.
For a craft business that sold €700 worth of products to France last year, it plainly creates a very different economic calculation.
That is the real issue.
The recycling cost associated with a few kilograms of cardboard might be tiny. The fixed cost of proving compliance, maintaining registrations, appointing representatives and filing reports can be much larger than the environmental liability itself.
Aren’t small sellers exempt?
There is no general PPWR exemption for small businesses from packaging EPR.
That distinction matters because several genuine small-business concessions elsewhere in the Regulation are sometimes misreported as if they exempt small sellers completely.
They do not.
The 10-tonne rule is not an exemption
Article 44 contains simplified reporting provisions for a producer that places less than 10 tonnes of packaging in a Member State during a calendar year.
But that is a reporting simplification.
It does not say that a seller under 10 tonnes is exempt from registration, EPR or the authorised-representative requirement.
For many small ecommerce businesses, 10 tonnes sounds enormous. A tiny seller might ship only 50 kg or 100 kg of packaging into a particular country in an entire year.
That seller can still fall within the EPR system.
Micro-enterprises do receive some PPWR concessions
The PPWR does contain targeted exceptions for micro-enterprises.
Under the EU definition used by the Regulation, a micro-enterprise generally has fewer than 10 employees and annual turnover or balance-sheet total not exceeding €2 million.
Among other things, PPWR contains special treatment for micro-enterprises in certain manufacturer responsibilities and future reuse obligations. For example, some reuse targets contain an exemption where a micro-enterprise places no more than 1,000 kg of packaging on a Member State’s market during the relevant year.
But none of that amounts to a blanket exemption from packaging EPR for small ecommerce sellers.
PPWR even specifically states that producer responsibility organisations must treat producers equally regardless of size and must avoid imposing disproportionate burdens on producers of small quantities. That wording recognises the problem — but it does not remove the underlying obligation.
Didn’t the EU try to exempt these businesses?
This part of the story is true.
In December 2025, the European Commission proposed temporarily suspending Article 45(3), the rule requiring EU-based producers to appoint an authorised EPR representative in every other Member State where they sell directly to end users.
The proposed suspension was supposed to last until 1 January 2035, while the EU worked on a broader reform of EPR under its forthcoming Circular Economy Act.
The Commission’s reasoning was unusually direct: fragmented national EPR systems and repeated authorised-representative appointments were creating unnecessary administrative costs and barriers to the Single Market.
In other words, the Commission identified essentially the same problem small online sellers are now complaining about.
The Member States said no
The proposal then went to the Council, where the governments of the EU Member States negotiate legislation.
It did not progress.
On 24 June 2026, the Council confirmed that negotiations on the two proposals dealing with EPR representatives had been discontinued because of strong reservations from an overwhelming majority of Member States. The Council also pointed to the forthcoming broader review of EPR rules under the Circular Economy Act.
So describing the requested relief as having been “turned down” is broadly correct.
More precisely:
The Commission proposed suspending the requirement, but an overwhelming majority of Member States opposed proceeding with that suspension in the Council.
But the story is not finished
The European Parliament is still considering the proposal.
Parliamentary discussions have included a narrower alternative under which relief would apply specifically to micro and small businesses, rather than to every EU-established producer.
As of 15 August 2026, however, that is not law.
The Parliament’s official legislative file still shows the proposal as awaiting the responsible committee’s decision. A parliamentary position is expected later in 2026.
Small sellers therefore should not currently operate on the assumption that an exemption exists.
It does not.
There is another complication: the new registration system itself is still being built
PPWR requires every Member State to establish a national producer register, but the timetable is tied to a Commission implementing act establishing the common registration and reporting format.
That implementing act was supposed to be adopted by February 2026. Instead, the draft was only published for feedback on 6 August 2026. Member States then have 18 months after the first implementing act enters into force to establish the PPWR registers required by Article 44.
That means the supposedly harmonised PPWR registration infrastructure is not yet fully in place.
At the same time, countries already have national packaging-EPR systems. Germany’s LUCID register, for example, is operating and has already been updated for PPWR responsibilities.
The practical result is a transition period in which businesses face a new EU Regulation while still dealing with different national systems.
That is precisely the sort of fragmentation the Regulation was intended eventually to reduce.
Marketplaces make the issue difficult to ignore
There is another reason ecommerce sellers need to pay attention.
PPWR requires qualifying online marketplaces to obtain packaging-registration information from producers before allowing them to sell to consumers in the EU. Producers must also provide a self-certification confirming compliance with their EPR obligations in the destination Member State.
That creates a powerful enforcement mechanism.
A tiny merchant may never receive a letter from a foreign environmental authority.
But if Amazon, Etsy or another marketplace requires a valid producer registration number for a destination country, non-compliance can become a commercial problem immediately.
What this means for a small EU webshop
For small sellers, the biggest PPWR issue is therefore not a mysterious €1,000 tax.
It is fixed compliance cost multiplied by the number of countries served.
A business should determine, country by country:
1. whether it sells directly to an end user there;
2. whether it is the “producer” for the packaging under the PPWR;
3. what national EPR registration or producer-responsibility scheme currently applies;
4. whether a local authorised representative is currently required;
5. what packaging quantities must be reported;
6. what actual recycling contributions are due; and
7. what part of the process can realistically be handled without paying a commercial compliance provider.
Small sellers should also keep packaging data separated by destination country and material — for example cardboard, plastic, glass and aluminium — because PPWR reporting is ultimately based on quantities of packaging placed on each national market.
Most importantly, do not interpret “less than 10 tonnes” as meaning “exempt.” It is principally a simplified reporting threshold.
Could this discourage small businesses from selling across the EU?
That risk is difficult to ignore.
The environmental principle behind EPR is reasonable: if a business introduces packaging into a country’s waste stream, that business should contribute to the cost of collecting and recycling it.
The difficulty is applying a system designed to recover waste-management costs to very small cross-border transactions.
A €20 order might contain only a few cents’ worth of packaging-waste liability.
But if selling that order requires participation in a national scheme, administrative reporting and a separately contracted representative, the compliance cost can dwarf both the packaging cost and the profit on the sale.
The Commission itself has acknowledged that these fragmented EPR arrangements can create barriers within the Single Market and specifically proposed removing the mandatory representative requirement for EU-based cross-border sellers.
The Council’s refusal to proceed means that, at least for now, small businesses are caught between those two policies:
the EU wants both a circular packaging economy and a frictionless Single Market, but its current packaging-compliance architecture can make very small cross-border sales disproportionately expensive.
What happens next?
The present rules should not necessarily be assumed to be the final form of EU packaging EPR.
The European Parliament is still working on the Commission’s proposal, while the Commission intends to address the wider structure of Extended Producer Responsibility through the forthcoming Circular Economy Act. The Council specifically cited that forthcoming reform when it stopped work on the temporary suspension.
For now, however, Article 45(3) remains part of the applicable PPWR.
Businesses should therefore distinguish carefully between:
what politicians have proposed, what may change later, and what the law says today.
The bottom line
The viral claim that “PPWR makes every small seller pay €1,000 to register in every EU country” is false.
There is no €1,000 PPWR registration charge.
But dismissing the entire story as misinformation would also be wrong.
For EU businesses selling packaged products directly to end users in other Member States, the PPWR can create country-by-country EPR responsibilities. Under the rules currently in force, that can also include appointing an authorised representative in each relevant destination Member State.
Commercial companies may charge hundreds or around €1,000 per country to manage those obligations. Those are private compliance costs rather than an EU fee, but for very small cross-border sellers the economic effect can still be severe.
The European Commission recognised that problem and proposed suspending the representative requirement. An overwhelming majority of Member States opposed proceeding with the proposal in the Council. Parliament is still considering a narrower form of relief, particularly for micro and small businesses.
So for small online sellers, the right conclusion is neither “TikTok panic” nor “nothing to worry about.”
It is this:
The €1,000 figure is misleading. The underlying cross-border compliance burden is real. And the EU has not yet resolved it.
This article provides general information about the PPWR and EPR framework and is not legal advice. National packaging requirements and implementation arrangements should be checked for each country in which a business sells.
Primary sources and further reading
– Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation: Articles 44 and 45 contain the producer-register and extended-producer-responsibility provisions discussed above.
– European Commission PPWR guidance: explains who is considered the producer and in which Member State EPR costs arise.
– European Commission PPWR information and FAQ: confirms the general application date of 12 August 2026 and the phased implementation of other requirements.
– European Commission proposal COM(2025) 982: proposed suspending the mandatory authorised-representative requirement until 2035.
– Council of the EU, June 2026: confirms that negotiations on the EPR-representative suspension were discontinued because of strong reservations from an overwhelming majority of Member States.
– European Parliament legislative file 2025/0395: shows that Parliament’s consideration of the proposed suspension remains pending.
– German Central Agency Packaging Register: confirms that LUCID registration itself is free while separate system-participation costs may apply.